Third-party payments involve invoices paid by entities or individuals that are not the original parties to the agreement. While there may be legitimate reasons for such arrangements, third-party payments are also sometimes used to obscure the origin of funds or to conceal the involvement of certain parties. As such, they present a potential method for money laundering.
Accepting payments from third parties carries risks and can expose recipients to legal and compliance risks. In some circumstances, this could result in liability for money laundering offences. Additionally, receiving third-party payments can complicate efforts to detect illicit financial activity, particularly when they obscure the transaction trail.
In a news article of 16 May 2025, the Dutch Central Bank (De Nederlandsche Bank, DNB) emphasised the importance of recognising the risks associated with third-party payments. DNB urged financial institutions to take timely and appropriate measures to mitigate these risks.
This concern was also highlighted in DNB’s Integrity Supervision in Focus 2025 (Integriteitstoezicht in Beeld 2025), published on 31 January 2025. This report outlines key integrity risks across various sectors, including banks, insurers, and payment service providers.
DNB notes that many of these risks are becoming increasingly cross-sectoral. This is mainly due to the payment chain becoming increasingly complex and opaque. This complexity is especially pronounced in transactions that span multiple countries, sectors (such as correspondent banks, payment service providers, and cryptocurrency service providers), or payment methods. Criminals exploit this complexity to hide illegal funds by using intermediaries, third-party structures, and converting funds into cryptocurrencies. DNB stresses that this requires continuous adaptability and vigilance from all ‘gatekeepers’ in the payment chain.